Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Service of notices uploaded solely on the statutory GST electronic portal and denial of personal hearing were challenged as breaches of the principles of natural justice; the court noted personal hearing obligations and adequacy of electronic service are central. The court emphasised that writ jurisdiction under Article 226 is discretionary and ordinarily inappropriate where an effective statutory appellate remedy exists; because the appellate remedy under the GST framework was available and adequate, the petition was dismissed as not maintainable, with liberty to pursue the prescribed statutory appeal.
Service of notices uploaded solely on the statutory GST electronic portal and denial of personal hearing were challenged as breaches of the principles of natural justice; the court noted personal hearing obligations and adequacy of electronic service are central. The court emphasised that writ jurisdiction under Article 226 is discretionary and ordinarily inappropriate where an effective statutory appellate remedy exists; because the appellate remedy under the GST framework was available and adequate, the petition was dismissed as not maintainable, with liberty to pursue the prescribed statutory appeal.
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